Reid Wealth Management Pty Ltd
This document outlines Reid Wealth Management’s policy with respect to handling the personal information we collect. ‘Reid Wealth Management’, ‘we’, ‘us’ or ‘our’ refers to Reid Wealth Management Pty Ltd (ABN 16 636 730 777 – AFSL 520048).
Personal information is information or opinion that allows others to identify you. It includes, but is not limited to, the following: your name, age, gender, contact details, financial information (including tax file number), information on your health, sexual orientation, philosophical or religious beliefs, race or ethnic origin, political opinions, details of membership of professional associations or trade unions, and genetic or biometric information.
We collect personal information to provide you with the products and services you request as well as to provide information on other products and services offered by, or through us. The law requires us to collect and retain personal information. You can seek access to the personal information we hold about you. If the information we hold about you is inaccurate, incomplete, or outdated, please let us know so that we can correct it (refer to contact details in this document.
The kinds of personal information we collect and store will depend on what products and services you request from us. We will collect, maintain, use, and disclose personal information which is necessary for us to adequately provide the services you have requested including:
- preparation and provision of initial financial advice;
- preparation and provision of ongoing financial advice;
- placement of financial products including purchase, variation, or redemption of investments;
- provision of a financial service, such as actioning share buy/sell instructions;
- provision of a financial service, such as purchase, variation, or cancellation of insurance products;
- set up and administration of a Self-Managed Super Fund (SMSF);
- providing assistance with ancillary services such as Centrelink;
- providing assistance with the coordination of other providers or experts such as solicitors, accountants etc.
As well as providing us with information upon which to provide a customised solution to your needs and objectives, we are required under the Corporations Act 2001 (Cth) and the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) to collect and hold this information.
How and why we collect information
Generally, we will not collect personal information about you except when you have knowingly provided that information to us or have authorised a third party to provide that information to us.
Sometimes we collect information about you from other sources. We may collect information about you that is publicly available (for example from public registers or social media). However, in most cases collection of your personal information will be via face to face interviews, over the telephone, email or by way of your completion of a financial fact find.
From time to time, other service providers may provide us with your information for the purpose of our providing a service to you (referral). In this case we will contact you to determine if we can be of any assistance.
We may seek your express permission to collect information from other entities such as product providers, accountants, solicitors, etc where this information may not be currently available to you. If we were to obtain information that is not information that could have been provided or authorised for collection by you, we will de-identify and destroy this information unless it is unlawful to do so.
Identification documentation is required for collection by law under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), as we are required to know our clients. In some instances, we are required to verify this documentation against other records. For instance, identification for Australian companies, trusts or registered co-operatives may need to be verified by a search of records held by regulatory bodies such as Australian Securities and Investments Commission (ASIC) or the Australian Taxation Office (ATO) etc.
Use and disclosure of information
We will not use or disclose personal information collected by us for any purpose other than:
- the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
- where you have consented to such disclosure; or
- where the APP authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by, or on behalf of, an enforcement agency or regulatory body.
We are obliged to maintain records which include personal information and make those records available for inspection by [the] ASIC or other regulators under a relevant law. If we provide information for the purpose of law enforcement activities, we will make a record of that provision.
If you have any concerns in this regard, you should contact us by any of the methods detailed in this document.
If you chose not to provide your information
The effectiveness of our services is specifically dependent on information you provide and it being relevant, complete, accurate and up-to-date. Without this, our services may not meet your needs or may result in unforeseen financial consequences. If you elect not to provide us with your personal information, as and when requested, we may not be able to provide you with financial services.
We may use personal information collected from you for the purpose of providing you with direct marketing material; however, if you do not wish to receive such information you can request not to receive it. Simply contact us by any of the methods detailed in this document. There is no cost for this request, however, please allow two weeks for your request to be actioned.
Reid Wealth Management Pty Ltd adheres to the Spam Act 2003 (Cth), accordingly, we will:
• obtain your consent before sending an electronic message to you (this can be express or inferred);
• provide sender identification (so that you know who sent the message); and
• provide you with the option to unsubscribe.
Disclosing information to other parties
In order to provide our services, we may disclose your personal information to external parties, including, but not limited to:
- other entities who refer your business to us;
- external service providers such as superannuation fund trustees, insurance providers, and product issuers for whom we act as agent (so that they may provide you with the product or service that you seek or in which you have an express interest);
- auditors we appoint to ensure the integrity of our operations;
- suppliers from whom we order goods and services to enable us to provide our service to you (paraplanning and information technology support);
- other persons acting on your behalf including your accountant, solicitor, executor, administrator, trustee, guardian, or attorney;
- if required or authorised to do so under law, law enforcement agencies, regulatory bodies, and government organisations;
- medical assessment services where you have sought insurance for the purposes of underwriting an insurance policy;
- other organisations, who, in conjunction with us, provide their products and services (so that they may provide their products and services to you).
In all circumstances where personal information may become known to our contractors, agents and outsourced service providers, there are confidentiality arrangements in place. Contractors, agents and outsourced service providers are not able to use or disclose personal information for any purposes other than our own.
We take our obligations to protect client information very seriously and we make every effort to deal only with parties who share and demonstrate the same attitude.
Sending personal information overseas
We may disclose your personal information to contractors overseas to help us provide services to you. These organisations are bound by confidentiality arrangements. If we do so, you should be aware of the following:
- your personal information may be accessed by our agents in other countries, if that becomes necessary to deliver our services to you. This access is via secure internet connection or in some instances by email;
- from time to time, information may be loaded to the cloud for storage or access through programs such as Dropbox etc; and
We take reasonable steps to ensure that overseas recipients adhere to the APP.
Website, Social Media and Email
When you visit our website, details may be recorded about your visit, such as time and date, your computer IP address, pages accessed, time spent on page and type of browser.
If you provide information on a social media platform, including, but not limited to, LinkedIn, Facebook, Twitter, and Instagram, we may hold, store, and disclose this information for the purposes of marketing or the provision of services to you.
This information is used in an anonymous format for statistical purposes and as such cannot identify you individually, unless we have sought permission from you to do so. Where you don’t want this to happen, please notify us.
Government Related Identifiers
We will not adopt as our own any identifiers that you may provide to us such as TFNs, Centrelink, Medicare numbers etc. If you have provided us signed consent, we may hold your identifiers on file so that we can provide ongoing services to you. If you chose not to provide this consent, we will not hold this information on file.
The circumstances in which an organisation may use or disclose government related identifiers are narrower in scope than the circumstances in which an organisation may use or disclose other personal information. Government related identifiers will not be disclosed except in the following circumstances:
- where use or disclosure is reasonably necessary for the organisation to verify the identity of the individual for the purposes of the organisation’s activities or functions;
- to verify that an individual is who or what they claim to be, for example, to verify their name or age;
- to fulfil our obligations to an agency or a State or Territory authority;
- as required or authorised by or under an Australian law or a court/tribunal order;
- where use or disclosure may lessen or prevent a serious threat to life, health, or safety;
- when taking appropriate action in relation to suspected unlawful activity or serious misconduct;
- when disclosure of a government related identifier to an enforcement body is requested for enforcement related activities; and
- as prescribed by regulations.
Accessing and Correcting your Information
Our goal is to ensure that the personal information we hold about you is accurate, secure, complete and up-to-date. Please contact us if you believe that the information, we have about you is not complete, accurate or up-to-date.
You can ask us to update or change information in your file at any time. Prior to providing this access we will require you to provide evidence of your identity. We may ask you to put your request in writing and any charge we make for providing access will be reasonable.
We will endeavour to respond to any request for access within 14-30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.
We may take steps to update information, for example, an account balance from your account service provider where you have provided us with access rights or an address or contact number from publicly available information such as telephone directories or websites.
If you ask, we will tell you what personal information we hold about you within your client file and what we do with it. On receipt of your request we will, subject to the limitations outlined below, facilitate access to you by allowing an inspection of your client file in person, or by providing copies or an accurate summary of relevant documents, depending on what we believe is most appropriate in the circumstances.
If for whatever reason we refuse to change information we hold on your file, we will arrange for a statement from you to be associated with the relevant information so that it can be included in any future use or disclose of that information should you wish to do so.
When we make reference to your client file we are referring to documents, including, but not limited to:
- data collection forms;
- written communications (such as letters and emails) from you to us and from us to you;
- Statements of Advice (SoAs), Records of Advice (RoAs);
- tax returns;
- transaction letters;
- signed authorities;
- investment, superannuation and personal insurance applications or statements produced by the issuers of financial products, and fee invoices.
In accordance with the APP, we will not provide you with access to your personal information if:
- providing access would pose a serious threat to the life or health of a person or the health and safety of the public;
- providing access would have an unreasonable impact on the privacy of others;
- the request for access is frivolous or vexatious;
- the information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
- providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
- providing access would be unlawful;
- denying access is required or authorised by or under Australian law or by court/tribunal order;
- Reid Wealth Management has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to its functions or activities has been, is being, or may be engaged in, and giving access would be likely to prejudice the taking of appropriate action in relation to the matter;
- providing access is likely to prejudice actions being conducted by an enforcement agency; or
- providing access would reveal evaluative information generated within Reid in conjunction with a commercially sensitive decision-making process.
In the event we refuse your request to access to your personal information we will provide you with a written explanation for that refusal.
Keeping your Information Secure
Your personal information is generally held in your client file and on our computer database. We will always seek to ensure that your personal information is protected from misuse, loss, unauthorised access, modification, or disclosure.
At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential. Our security measures include, but are not limited to:
- educating our authorised representatives and staff as to their obligations with regard to your personal information;
- all hard copy files are stored in lockable cabinets/ rooms;
- access to our premises is controlled by only allowing authorised personnel to access those locations where personal information is stored;
- all computer-based information is protected through the use of access passwords on each computer and screen saver passwords;
- client data is backed up each evening and stored securely off site;
- encrypting data sent from your computer to our systems during internet transactions, and customer access codes transmitted across networks;
- employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;
- using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing; and
- providing secure storage for physical records.
In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in our secure storage facility for a period of 7 years in order to comply with legislative requirements.
Where information we hold is identified as no longer needed for any purpose, we ensure it is effectively and securely destroyed.
The information in this document is considered to be true and correct at the date of publication. Changes to circumstances after the time of publication may impact on the accuracy of the information held.